As a supplier purchasing a CBAM-impacted product and reselling it to a customer in Europe, without producing it ourselves, are we impacted by CBAM?

Understanding CBAM implications for intermediary suppliers of CBAM goods

1. Direct CBAM obligations:
   • If you are not the entity declaring the goods for import into the EU, you do not have direct reporting or financial obligations under CBAM.
   • The primary CBAM obligations (reporting and future certificate surrender) fall on the importer of record or their customs representative.
2. Data transmission role:
   • You will likely need to act as an intermediary for emissions data.
   • You'll need to obtain detailed emissions information from your supplier and pass it on to your EU customer or the importer.
3. Data requirements:
   • The information you'll need to obtain and transmit includes: a) Embedded emissions (both direct and indirect) of the product b) Production process details c) Any carbon pricing applied in the country of origin
4. Due diligence:
   • While you're not producing the goods, you may need to ensure the accuracy of the emissions data you're transmitting.
   • Consider how you will verify the information provided by your supplier.
5. Contractual considerations:
   • Review and possibly update your contracts with both suppliers and customers to address CBAM-related data requirements and responsibilities.
6. Pricing implications:
   • Be aware that CBAM may affect the pricing of the products you're selling.
   • Your EU customers may seek products with lower embedded emissions to reduce their CBAM costs.
7. Preparation steps:
   1. Engage with your suppliers to ensure they can provide the necessary emissions data.
   2. Develop systems to efficiently collect, verify, and transmit emissions data.
   3. Familiarize yourself with CBAM requirements for the specific products you're dealing with.
8. Value-added services:
   • Consider offering CBAM-related services to your customers, such as assistance with data collection and reporting, to maintain your competitive edge.
9. Future considerations:
   • Stay informed about potential changes to CBAM, as future iterations might affect intermediary suppliers more directly.
   • Be prepared for increasing scrutiny on the accuracy of emissions data throughout the supply chain.

Remember, while you may not have direct CBAM obligations, your role in the supply chain is crucial for ensuring accurate emissions reporting. By proactively managing this process, you can add value for your customers and maintain your position in the market. Always stay updated with the latest CBAM developments, as regulations may evolve over time.